The Company is a recruitment business which therefore provides teacher-finding services to its schools, and teaching position-finding services to its schools. The Company must therefore process personal data (including sensitive personal data) so that it can fully provide these services – in doing so, the Company is responsible for the persona data.
You may give your personal details to the Company directly, such as on an application or registration form or via our website, or we may collect them from another source such as a jobs board and other recruiters. The Company must have a legal basis for processing your personal data and must process your personal data for the purposes of providing you with teaching position-finding services, or teacher-finding services and/or information relating to teaching positions or teachers relevant to you. We will only use your personal data in accordance with the terms of the following Notice.
Teachers(s)” means any individual who registers with the Company or contacts an employee of the company for the purposes of obtaining a teaching position in China.
“School(s)” means any organisation and individual/employee of that organisation that the Company provides recruitment services to. This can be any educational institution.
Recruiter(s) means any third-party that has an exact or similar business whereby they provide similar or exact services to ours. This can mean facilitating recruitment needs or schools or helping teachers find schools to work in.
“Website User(s)” means anyone using our website to view the services we offer and interacts with any part of the website.
“Data Protection Legislation” means all data protection laws including the Data Protection Act 1998 and the General Data Protection Regulation (EU/2016/679).
“personal data” and/or “personal information” means any information relating to an individual who can be identified, such as by a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“organisational data” means any information relating the school the Company is providing or may be providing services to. This can include documentation to prove the school’s legal status, qualify its HR representatives, location data, online identification, website, physical premises, and information related to being able to provide legal employment.
“process/processing” means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“sensitive personal data” means personal data revealing racial or ethnic origin, political opinions, records of criminal convictions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions.
* For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data.
“Supervisory authority” means an independent public authority which is responsible for monitoring the application of data protection. In the UK the supervisory authority is the Information Commissioner’s Office (ICO).
The information we collect about you
We may ask you for the following information depending on the method you interact with us as described below:
- personal and contact details (for example your first name, second name, email address, current physical address date of birth, gender);
- information about your current employment status, VISA status in China and other necessary information to determine legally placing you into a school;
- personal and contact details you give us when subscribing to receive emails, newsletters or marketing information from us;
- during pre-assignment vetting we will request details from you including, your name, your work history, qualifications, contact details (such as email, telephone number and home address), details required for equality and discrimination legislation checks and your personal preferences, choices and requirements specific to particular requests or services;
- details of your education, employment history, references, right to work and other information you tell us about yourself (e.g. the information contained within your CV and covering letter) when you engage with us for the provision of services;
- information from social media activity (such as likes, shares and tweets) when you interact with us on social media;
- additional information which you provide voluntarily and/or which we may ask from you to better understand you and your interests.
- contact details or those of individuals at your organisation (such as names, telephone numbers and email addresses) to enable the provision of services and to facilitate our relationship with you, including relevant marketing.
- FEC Certificates and proof of legal organisation status within Mainland China
- Additional information which you may provide voluntarily, or we may access through your website for us to better market your school and vacancies
- We collect generic information about which country our users are viewing our website from, and which websites they come from. Information collected from website users is not to an individual user and is just quantifiable as an aggregate over a day, week, month and year.
How, when and why do we collect your personal information
We have create a non-exhaustive list of the uses the Company may have for your personal data, and the different reasons we may use it.
If you are a teacher, the company will process your personal data for purposes of providing you with teaching-finding services. This service will include providing you with teaching position recommendations and submitting your application to potential schools. The Company may also use your personal data for marketing purposes. The Company may also use your personal data for Diversity Monitoring, Equality, or as required by law, regulatory bodies or for tax or audit purposes.
If you are a Teacher seeking employment and have applied for a position or have submitted your CV to the Company, in order to provide you with work-finding services, the Company is required to process your personal data. This may include carrying out any relevant reference checks which are necessary for the purposes of you gaining employment. If you successfully obtain employment, the Company will require to process your personal data for administration purposes. We may also provide job recommendations we think you may be interested in. To ensure that any recommendations are specifically tailored to your requirements, the Company may process your personal data for this purpose. The Company regards all the above as being legitimate interests in running a recruitment business and to provide appropriate recruitment services.
The company may collect your personal information from you apply for a teaching position through us (or otherwise are in contact with us) by:
- you responding to an advert on a job board or other website;
- by you directly contacting our business;
- when you speak to one of our consultants by telephone, WeChat or email; or
- another recruiter or organisation passes your details to us.
Why do we collect your Personal Information?
We collect and use your Personal Information because it is necessary to obtain certain details including Personal Information from you in the teaching position-finding process and it is in our legitimate interests in the course of operating our business, including:
- responding to your queries;
- providing work-finding services and/or information to you;
- transmitting Personal Information between our offices or functions for internal administrative purposes;
- hosting and maintaining our websites;
- ensuring network and information security; and/or
- carrying out direct marketing.
However, we will only collect, use and handle your Personal Information when:
- it is necessary for our legitimate interests in connection with carrying out our business, if, in each case, these interests are in line with applicable law and your legal rights;
- and/or where you have agreed;
- and/or where this is necessary for legal obligations which apply to us.
If you are a School, the Company will process your personal data and organisational data for the purposes of providing you with recruitment services as per our agreed terms of contract. The Company may also use your personal data for marketing purposes or as required by law, regulatory bodies or for tax or audit purposes.
The Company will store your and your employees’ personal data for the purposes of ensuring that you are provided with suitable Teachers for job positions. The Company will also store records of role requirements, meetings, emails and conversations to ensure that the Company continues to provide you with relevant recruitment services. The Company considers the above as being in our legitimate interests in running a recruitment business and providing appropriate recruitment services.
How and when do we collect your Personal Information?
We may collect your Personal Information and Organisation Information when required in the course of our business relationship with you.
Why do we collect your Personal Information?
We collect and use your Personal Information and Organisation Information because it is necessary to obtain certain details:
- to offer services to you or to obtain support and services from you;
- to perform certain legal obligations;
- in the performance of our contract with you;
- to help us to target appropriate marketing campaigns;
- in transmitting Personal Information between our offices or functions for internal administrative purposes;
- in hosting and maintaining our websites;
- in ensuring network and information security; and/or
- in carrying out direct marketing.
However, we will only collect, use and handle your Personal Information when:
- it is necessary for our legitimate interests in connection with carrying out our business, if, in each case, these interests are in line with applicable law and your legal rights; and/or
- where you have consented;
- in the performance of our contract with you; and/or
- it is necessary for legal obligations which apply to us.
How we use the Personal Information that you provide to us
Where necessary and appropriate for our business purposes and in accordance with regulatory requirements, and where if required we have an appropriate processing agreement in place, we may use your personal data for:
- The performance of our contracts with clients and suppliers;
- Third party professional advisers such as lawyers, auditors and accountants and third party service providers and consultants performing technical services for us (such as IT support functions, testing and development work and external consultants);
- Where necessary in using technology systems and document storage; and
- In using marketing services platforms.
Marketing Opt-Out: you can opt-out from receipt of marketing communication at any time free of charge by using the “unsubscribe” option included in any marketing e-mail or other marketing material received from us.
We undertake the following processing of your Personal Information on the legal basis that it is necessary to perform the contract with you and to provide the services we have agreed to provide to you. Where we have not entered into a contract with you, we may also carry out this processing because in that pre-contractual stage where we consider it is necessary in our legitimate business interests in order to deal with requests, enquiries or comments you have made to us.
Pre-service vetting – we collect your Personal Information which you provide to us when applying for a teaching or registering for our job-finding services to comply with our (and schools’) legal obligations regarding your right to teach in Mainland China and any necessary qualifications for roles. We may also process your Personal Information for this purpose where we consider it necessary for performance of the contract with you, or otherwise with your consent.
Submission of details to clients – If you apply for a specific teaching position, request to be put forward for a teaching position, or if you have asked us to put you forward for suitable teaching positions, we will share some of your personal information including your name, CV, work history and qualifications with our schools offering potential teaching positions that might be suitable for you.
Other lawfully permitted processing – We may also use any Personal Information that you provide to us for example to schools or any other company who you ask us to approach on your behalf for teacher-searching purposes. If you choose not to provide Personal Information requested by us, we may not be able to provide you with the services and/or information you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information. We will where possible anonymise or aggregate such data for reporting purposes.
We undertake the following processing of your Personal Information with your consent.
Marketing – where legally permitted to do so where you have provided us with your contact details and have agreed to be contacted for marketing purposes, we may contact you by telephone or by post for marketing purposes relating to our services, our website, and/or to research opinion on proposed business developments. Your agreement to the use of your Personal Information for these purposes is optional and if you fail to provide your agreement, your use of our work-finding services will not be affected.
Recruiters & Third Parties we may share your personal data with
Some services that we provide require the involvement of recruiters or third parties. We have carefully selected these and have taken steps to ensure that your Personal Information is adequately protected.
Where we liaise with third party companies or individuals to process Personal Information provided by us on our behalf for business functions, including (without limitation) IT development, hosting our data on cloud platforms, legal, accounting, audit, consulting and other professional service providers, and providers of other services related to our business.
International Transfers of your Personal Information
Some of our subsidiaries or external recruiters are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.
The length we store your personal data for
The Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services.
We support Teachers over many years and potentially throughout their careers and the reason for which we retain the Personal Data can be an ongoing purpose. We also work schools over long periods of time and retain Personal Data as part of these relationships. If we have not had meaningful contact with you for an extended period of time, we will delete Personal Data.
It is important to us that you are in control of your own information. As a result, you have the following controls:
- Right of Access: You may request access to or copies of the Personal Information that we hold about you. If you would like to exercise this right, please contact us via our contact form online.
- Right to Rectification: If you believe that any information we have about you is incorrect or incomplete, please contact us via our contact form online as soon as possible. We will take steps to seek to correct or update any information if we are satisfied that the information we hold is inaccurate.
- Right to Erasure: You may request that your Personal Information be deleted, where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such information. If we do delete your data we will generally assume you would prefer us to keep a note of your name on our register of individuals who would not prefer to be contacted and we do keep a record of names of those asking for their information to be erased. If you prefer us not to do this, you are free to say so;
- Right to Restrict Processing: You may request that we restrict the processing of your data in certain circumstances, for example if you are concerned about the accuracy of the data or how it is being used;
- Right to Object to Processing: To the extent we are processing your Personal Information to meet our legitimate interests (as set out above), you may object to the processing of your Personal Information by us. If we are unable to demonstrate our legitimate grounds for that processing, we will no longer process your Personal Information for those purposes;
- Right to Withdraw Marketing Consent: You may withdraw your consent to receiving marketing contact at any time by contacting us online via our contact form.
- Right of Data Portability: This only applies to information you have given us. You may have the right to request we transfer the information you gave us from one organisation to another or give it to you;
- Right not to be Subject to Automated Individual Decision-Making:You have the right not to be subject to a decision based solely on automated processing, including profiling, if such profiling produces a legal effect concerning you or similarly significantly affects you,
- Right to Complain: If you are unhappy with the way that we have handled your data, you can make a complaint to the Information Commissioners Office (ICO) which is the UK authority responsible for data protection. Contact details are available online.
Security and Confidentiality
We employ appropriate security measures to help protect your Personal Information and guard against access by unauthorised persons. Information storage is on secure computers in a secure environment, or in secure, locked storage in the case of hard copy information. The information is encrypted wherever possible and we undergo periodic reviews of our security policies and procedures to ensure that our systems is secure and protected. However, the transmission of information via the Internet is not completely secure so we cannot guarantee the security of your information when it is transmitted to our website or from third party websites such as job boards.
Updates to this Privacy Notice
This Privacy Notice may be updated periodically to reflect changes in our privacy practices and legal updates. We will indicate at the top of the notice, which is posted on our websites, when it was most recently updated.